Michael:
The contract is your only and final authority on what is required. The vendor
is legally bound by the letter of the contract, nothing more and nothing less.
For every question about performance, reliability, quality, packaging,
marking, etc, there is a section of the contract that specifies the
requirement. If you are given a contract that doesn't define everything, then
you should clarify those grey areas with the procuring command at the very
start.
Well, that's how it's supposed to be in a perfect military world. In real
life, there are often vague and contradictory requirements that can be piled
into a contract. I spend a lot of my time providing EMC inputs for our
proposals and bids, trying to divine if the requirements set is really, really
what the customer wants to do. When a customer gives you a detailed
requirements list, you start out by assuming they know what they're doing.
However, when the evidence suggests the customer is wandering in circles in
the wilderness, then the best course is to arrive at a consensus through
gentle questioning. The whole idea is to be sure that, before my company
commits to a binding contract, we understand exactly what the customer
requires.
Marking is getting out of my area, but I know that there are contract line
items that will invoke the appropriate MIL or commercial standard for marking
(of the gadget, the gadget's box, the gadget's instruction manual, etc).
Administration of these contracts is a job unto itself, with a project manager
riding herd on all these requirements. That manager needs to view each line
item, and plan how his company will meet each item.
One bright spot about this process is that all DoD MIL Standards are available
free, online at:
http://assist.daps.dla.mil/quicksearch/
Sometimes, a MIL Standard will reference a commercial document, like an ANSI
or IEEE document, and those are not free.
Ed Price
[email protected] <blocked::mailto:[email protected]> WB6WSN
NARTE Certified EMC Engineer
Electromagnetic Compatibility Lab
Cubic Defense Applications
San Diego, CA USA
858-505-2780
Military & Avionics EMC Is Our Specialty
________________________________
From: [email protected] [mailto:[email protected]] On Behalf Of Michael
Loerzer
Sent: Thursday, April 09, 2009 1:39 PM
To: 'Grasso, Charles'; 'Ilarina, Alvin'; [email protected]
Subject: AW: US FCC Exemptions for Military Equipment?
Thanks for the received feedback.
The equipment is a “surveillance and target acquisition radar” (army,
air
force, navy). Applied EMC standard: MIL-Std. 461E, STANAG, VG. Also Machinery
Directive, Low Voltage Directive and other specifications.
I summarize that 47 CFR 15 is not applicable/mandatory (only the
contract).
But what is about “safety warnings and signs” and instructions?
I found DOD-STD MS18020B NOT 1:1996-05 or DOD-SPEC
MIL-DTL-87929C(1):2002-02.
Are also
· ANSI Z535.4 “American National Standard for Product Safety
Signs
and Labels”
· ANSI Z535.6 “American National Standard For Product Safety
Information in Product Manuals, Instructions, and Other Collateral Material”
applicable?
Mit freundlichen Grüßen
Yours sincerely
Dipl.-Ing. Michael Loerzer
Managing Director
Regulatory Affairs Specialist
[email protected] <mailto:[email protected]>
Fon: +49 30 3229027-50, Direct Call: -51
Mobile: +49 170 3229027
Fax: +49 30 3229027-59
www.Globalnorm.de <http://www.globalnorm.de/>
--------------------------------------
Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin
Geschaeftsfuehrer/Managing Director: Dipl.-Ing. Michael Loerzer
Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer:
DE251654448
Von: Grasso, Charles [mailto:[email protected]]
Gesendet: Donnerstag, 9. April 2009 20:50
An: Ilarina, Alvin; Michael Loerzer; [email protected]
Betreff: RE: US FCC Exemptions for Military Equipment?
If the military equipment is for sale to the general public then I
would have
thought that Part15
does apply!
________________________________
From: [email protected] [mailto:[email protected]] On Behalf Of
Ilarina, Alvin
Sent: Wednesday, April 08, 2009 3:08 PM
To: Michael Loerzer; [email protected]
Subject: RE: US FCC Exemptions for Military Equipment?
Michael,
15.103 is in 47 CFR 15 Subpart B which is for relevant to unintentional
radiators.
There are 2 classes of equipment here:
47CFR 15.3 (h) Class A digital device. A digital device that is
marketed for
use in a commercial, industrial or business environment, exclusive of a device
which is marketed for use by the general public or is intended to be used in
the home.
47CFR 15.3 (i) Class B digital device. A digital device that is
marketed for
use in a residential environment notwithstanding use in commercial, business
and industrial environments. Examples of such devices include, but are not
limited to, personal computers, calculators, and similar electronic devices
that are marketed for use by the general public.
Since these do not include “military,” I would expect that by definition
47 CFR Part 15 Subpart B is not applicable to military equipment.
Applicability of any of the other Subparts for Intentional radiators
would be
determined by the actual frequency spectrum used. Since you are dealing with
non-commercial equipment I would expect that the frequency band of operation
would fall in between the regulated bands for licensed and unlicensed devices.
Alvin
Disclaimer: The contents reflect the opinion of the author and are
meant for
entertainment purposes only.
________________________________
From: [email protected] [mailto:[email protected]] On Behalf Of Michael
Loerzer
Sent: Wednesday, April 08, 2009 10:13 AM
To: [email protected]
Subject: US FCC Exemptions for Military Equipment?
+++ Globalnorm-Konferenz „Product Compliance“, 09. und 10.06.2009 in
Berlin, www.product-compliance.com (english version follows) +++
Dear All,
We are assisting a German company to deliver a military system (c-band
radar
device, 4-8 GHz) to the USA. We are not sure about the “civil” regulatory
requirements for this system.
Questions:
· Are military devices generally exempted from FCC Part 15
(Section
15.103 Exempted devices includes no military equipment)? What about the device
mentioned afore?
· Does ANSI Z535.6-2006 also apply to military devices?
I would highly appreciate your response.
Mit freundlichen Grüßen
Yours sincerely
Dipl.-Ing. Michael Loerzer
Managing Director
Regulatory Affairs Specialist
[email protected] <mailto:[email protected]>
Fon: +49 30 3229027-50, Direct Call: -51
Mobile: +49 170 3229027
Fax: +49 30 3229027-59
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